In making the comparability determinations, the CFTC declined to make determinations for CFTC Regulations 23.600(c)(2) (Periodic Risk Exposure Reports) and 23.608 (Restrictions on Counterparty Clearing Relationships) in all jurisdictions, and CFTC Regulation 23.609 (Clearing Member Risk Management) in Hong Kong and Switzerland. Accordingly, the CFTC’s Division of Swap Dealer and Intermediary Oversight has issued temporary no-action relief from such requirements for non-US SDs and non-US MSPs established in the relevant jurisdictions until March 3, 2014. CFTC Letter No. 13-78 is available here.

Guy C. Dempsey Jr. concentrates his practice on derivatives and structured products and on bank regulation. He advises clients on derivatives transactions of all types across all asset classes, as well as on the corporate governance, regulatory, collateral, compliance, insolvency and litigation issues associated with such products.

Much of Guy’s work involves helping bank and non-bank clients analyze the details and impact of the Dodd-Frank Act. He maintains deep knowledge of the banking laws and regulations relating to capital markets activities.

While in law school, James was an editor of the Michigan Journal of International Law. He also served as a judicial intern to the Honorable Stephen J. Markman of the Michigan Supreme Court. http://www.kattenlaw.com/James-Brady